The ZES Unica, Italy’s single Special Economic Zone for the South, comes with a tax credit that can cover a large share of a new distribution centre: up to 60% for a small business in Campania, Apulia, Calabria or Sicily, and up to 70% in the province of Taranto. The trucks and vans that run out of that warehouse almost certainly don’t qualify, and road haulage as an activity is excluded.
This guide is for distributors running their own fleet in Southern Italy and for companies, Italian or foreign, planning a logistics hub there. It covers what the rules allow, why vehicles almost certainly fall outside them, how much the credit is really worth once claims are scaled back, and the 2027 notification window. The figures reflect Italy’s 2026 budget law, which extended the scheme to 2028 and added the regions of Marche and Umbria.
At a glance
- The credit covers new machinery, plant and equipment and the buildings of a production site inside the ZES Unica, but the building only counts up to the value of the non-property part.
- Road haulage for hire is excluded. Warehousing and wholesale distribution qualify, even with an in-house fleet.
- Trucks and vans are not on the list of eligible assets and, on the prevailing reading, don’t qualify. Vehicles have their own scheme, the Nuova Sabatini.
- The rates are ceilings. For 2025 the Italian Revenue Agency granted 60.38% of the credit claimed, later topped up to 75%, and the 2027 budget is less than half of 2026’s.
Who qualifies: the site counts, not the fleet
The scheme excludes businesses in transport, meaning ATECO codes 49 (land transport, including road haulage), 50 (sea and inland water transport, except two passenger codes) and 51 (air transport). ATECO is Italy’s version of the EU’s NACE classification. Warehousing and transport support activities are expressly kept in.
What matters is the ATECO code of the site where you invest, as declared to the Revenue Agency. Owning trucks doesn’t change it, because under EU state-aid rules only carriage for hire or reward counts as goods transport. A wholesaler that delivers with its own vehicles is still in wholesale.
| Activity at the site | ATECO code | ZES Unica tax credit |
|---|---|---|
| Road haulage for hire | 49 | Excluded |
| Warehousing, logistics and transport support services | 52 | Eligible |
| Wholesale with an in-house fleet (pharmaceuticals, food, drinks) | 46 | Eligible |
| Postal and courier activities | 53 | Not on the exclusion list; get the classification confirmed |
A haulier that also runs a warehouse may be able to claim for that site, on strict conditions. The two activities must be separate business units with separate accounts, and the subsidised assets must be used only for warehousing (circular 32/E of 2022). Set this up with your tax adviser before filing, not after.
What qualifies and the limits that matter
The law covers new machinery, plant and equipment, including through finance leases, plus land and the purchase, construction or extension of buildings used for the business. For a distributor that mostly means the new warehouse itself, cold rooms and refrigeration plant, automated storage systems and loading bays. Goods for resale and consumables are excluded.
The first limit is on property. Land and buildings can’t exceed 50% of the eligible investment, and the Revenue Agency reads this as meaning the property share it recognises can’t be larger than the non-property share (ruling 183/2025). A large shed with little plant inside only qualifies in part.
The second limit is on size. A project must be worth at least €200,000, counting ineligible costs too, and the credit is calculated on at most €100 million per project.
It also has to be an initial investment: a new site, the extension of an existing one, or a diversification. Opening a new hub counts. Simply replacing assets you already had, without expanding the site, does not. In “c” areas, meaning the eligible municipalities of Abruzzo, Marche and Umbria, large companies qualify only for investment in a new economic activity.
Two asset types need care. Under Italian accounting standards, forklifts are “internal means of transport” and sit among “other assets” alongside trucks, and racking, as warehouse fittings, can end up in the same class. If they are part of an integrated system, such as an automated warehouse, the picture changes. Settle the classification before you include them in the notification.
Why trucks and vans almost certainly don’t qualify
Nothing in the ZES Unica rules mentions vehicles, either to include or to exclude them. Three things point the same way, though:
- the law lists only machinery, plant, equipment and buildings;
- on the earlier tax credits for Southern Italy, the Revenue Agency excluded assets that are not booked as plant, machinery or equipment (ruling 145/2023), and Italian accounting standards put trucks and motor vehicles among “other assets”;
- the 2026 notification form has lines for plant, machinery, equipment and buildings, and none for vehicles.
The Agency made one exception in principle, for vehicles that earn income by being hired out, such as the boats of a yacht charter company (circular 32/E of 2022). A delivery van isn’t in that position. Absent specific guidance, excluding vehicles is the prevailing reading, and listing them in the notification risks having the credit challenged.
Vehicles have their own scheme. The Nuova Sabatini subsidises the financing of N1 and N2 commercial vehicles used in the business, and purchase grants are covered in the guide to commercial vehicle incentives. The ZES credit can be combined with other aid on the same costs only up to the EU maximum aid intensities. A warehouse under the ZES scheme and vans financed through the Sabatini are different costs, so the two don’t overlap; see our guide to stacking incentives and de minimis.
What it is really worth: rates and the pro-rata cut
Maximum rates depend on the region where the site is located and on the size of the business. For projects up to €50 million:
| Region | Small businesses | Medium-sized businesses | Large businesses |
|---|---|---|---|
| Campania, Apulia, Calabria, Sicily | 60% | 50% | 40% |
| Basilicata, Molise, Sardinia | 50% | 40% | 30% |
| Province of Taranto | 70% | 60% | 50% |
| Sulcis Iglesiente municipalities (Sardinia) | 60% | 50% | 40% |
| Abruzzo, Marche, Umbria (only municipalities in “c” areas) | 35% | 25% | 15% |
Those rates are ceilings, not what you will receive. Each year the scheme has a fixed budget: €2.3 billion for 2026, €1 billion for 2027 and €750 million for 2028. If claims exceed it, the Revenue Agency scales every claim back by the same percentage.
For 2025, with a €2.2 billion budget, the pro-rata allocation granted 60.3811% of the credit claimed. Italy’s 2026 budget law then added a top-up of 14.6189%, bringing the total to 75% for businesses that filed a separate notification in April and May 2026 and hadn’t received the Transizione 5.0 tax credit on the same investments. A small business in Campania on a 60% rate thus ended up with 45% of its investment, not 60%. The top-up was decided after the fact and is not guaranteed for later years.
The 2027 budget is less than half of 2026’s. If claims stayed at 2025 levels, roughly €3.6 billion of credit, a €1 billion budget would cover about 27% of them. That is a scenario, not a forecast, but a prudent business plan should not bank on the full rate.
There is a cash-flow catch too. The credit can only be used to offset Italian taxes and social contributions through the F24 payment form, after the Agency publishes the percentage granted. It turns into cash only as fast as the business has Italian taxes to pay, so a foreign group benefits through its Italian company or branch.
The deadlines
Businesses that notified investments for 2026 must file the supplementary notification between 3 and 17 January 2027, or lose the credit. For 2027 investments the calendar is:
| When | What |
|---|---|
| 31 March to 30 May 2027 | Notify the Revenue Agency of eligible costs incurred from 1 January and planned up to 31 December 2027 |
| By 31 December 2027 | Complete the notified investments |
| 3 to 17 January 2028 | File the supplementary notification confirming the investments actually made; miss it and the credit is lost |
| Within the following ten days | The Agency publishes the percentage granted, and the credit can then be offset |
The 30 May 2027 deadline falls on a Sunday. Under the rule applied in 2026 it would move to Monday 31 May, but don’t count on it.
The investment can start before the notification, provided it starts after the scheme came into force; the Agency confirmed this for a lease signed before the window (ruling 169/2026). If the warehouse doesn’t exist yet, you tick the “site not yet operational” box on the form.
Two obligations then run for years. The business must stay active in the zone for at least five years after the investment is completed, or the credit is clawed back, and the assets must be in use by the second tax year after purchase.
Worked example: a food distributor’s new hub in Apulia
A small fresh-food distributor opens a new refrigerated warehouse in Apulia, outside the province of Taranto, in 2027. The project costs €1,740,000:
| Item | Cost | Counted for the ZES credit |
|---|---|---|
| Warehouse building | €900,000 | Up to €600,000 |
| Cold rooms and refrigeration plant | €450,000 | €450,000 |
| Insulated loading bays and roller conveyors | €150,000 | €150,000 |
| Four refrigerated vans | €240,000 | No |
| Total | €1,740,000 | €1,200,000 |
The building only counts up to the value of the non-property part, €600,000 out of €900,000, and the vans are left out. The €200,000 minimum is measured before ineligible costs are removed, so the excluded share of the building still counts towards it.
The credit on paper is 60% of €1,200,000, which is €720,000. Applying the 2025 pro-rata alone, it would be about €435,000, or €540,000 with the top-up. In the scenario where 2027 claims stay at 2025 levels, with no top-up, it would be about €198,000. For the vans, the company can use the Nuova Sabatini to subsidise the financing.
These figures are illustrative and are not a calculation for a real case: asset classification and aid stacking need to be checked with a tax adviser.
Before you choose where to build
The credit covers part of the building and plant, once; the cost of delivering from the new warehouse is paid every day, for years. In Abruzzo, Marche and Umbria the choice of site matters even more, because the credit only applies in municipalities in “c” areas: two sites a few kilometres apart can be worth 35% in credit or nothing, and serve customers with different routes.
Put both in the same calculation. OptivoRoute supports multiple start and end depots, so you can plan the same orders from each candidate site before you sign. With a five-year obligation to stay in the zone, a poor choice of site is hard to undo.
The bottom line
The ZES Unica can cover a significant share of a new warehouse in Southern Italy, but it funds the building and its plant and, on the prevailing reading, not the fleet. Three mistakes to avoid: counting on the full rate when claims are scaled back; listing vehicles in the notification; building a shed with little plant inside, which only qualifies up to the value of that plant. For vehicles, use the Nuova Sabatini and purchase incentives, and make the choice on total cost of ownership, not on the size of the grant.
Frequently asked questions
Can a road haulage company use the ZES Unica tax credit?
Not for its transport business: ATECO codes 49, 50 and 51 are excluded. The sector is judged by the code of the site where the investment is made, though, so a warehouse run as a separate business unit, with separate accounts and assets used only for warehousing, needs to be assessed on its own with a tax adviser.
Do trucks and vans qualify for the ZES Unica credit?
On the prevailing reading, no. The law lists machinery, plant, equipment and buildings; trucks and motor vehicles are booked as “other assets”, and the notification form has no line for vehicles. For commercial vehicles, there is the Nuova Sabatini scheme.
What is the minimum investment for the ZES Unica?
The minimum is €200,000 per project, measured before ineligible costs are removed. The credit is calculated on at most €100 million per project.
When do you apply for 2027 investments?
Between 31 March and 30 May 2027, by notifying the Italian Revenue Agency. Then, between 3 and 17 January 2028, you must file a supplementary notification confirming the investments made, or the credit is lost.
Does a leased warehouse qualify?
In principle, yes, if it is a finance lease. The law allows it for plant, machinery and equipment, and according to the Revenue Agency it can also apply to buildings, including leases on buildings still under construction; in that case the investment counts from the handover of the building, which decides the year and the window (ruling 32/2026). The eligible cost is what the leasing company paid, excluding maintenance.
Can foreign companies use the ZES Unica tax credit?
The credit goes to businesses investing in a production site inside the zone, and it can only be offset against Italian taxes and contributions. In practice a foreign group uses it through the Italian company or branch that owns and runs the site.
How much credit do you actually get?
The maximum rate for your region and company size, multiplied by the percentage the Revenue Agency publishes after the supplementary notifications. For 2025 the pro-rata was 60.3811%, raised to 75% by a top-up in Italy’s 2026 budget law: a 60% rate became 45% of the eligible investment.
The next step
Before deciding where to open a new warehouse, compare the candidate sites on the routes that will run from them, not only on the credit. To do that on your own orders, talk to our team. For vehicles, a five-question incentive check shows which schemes apply to you.
Official sources, in Italian. Article 16 of Decree-Law 124/2023 · Law 199/2025, art. 1, paragraphs 438-449 · Italian Revenue Agency, who cannot claim the ZES Unica credit in 2026. Rates, windows and pro-rata percentages can change from year to year: check the rules in force with a tax adviser before planning the investment.